Angeline R. Brozovich and Frank V. Brozovich, Relators, vs. Commissioner of Revenue, Respondent

CourtSupreme Court of Minnesota
DecidedMarch 5, 2025
DocketA240547
StatusPublished

This text of Angeline R. Brozovich and Frank V. Brozovich, Relators, vs. Commissioner of Revenue, Respondent (Angeline R. Brozovich and Frank V. Brozovich, Relators, vs. Commissioner of Revenue, Respondent) is published on Counsel Stack Legal Research, covering Supreme Court of Minnesota primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Angeline R. Brozovich and Frank V. Brozovich, Relators, vs. Commissioner of Revenue, Respondent, (Mich. 2025).

Opinion

STATE OF MINNESOTA

IN SUPREME COURT

A24-0547

Tax Court McKeig, J. Took no part, Procaccini, J. Angeline R. Brozovich and Frank V. Brozovich,

Relators,

vs. Filed: March 5, 2025 Office of Appellate Courts Commissioner of Revenue,

Respondent. ________________________

Angeline R. Brozovich and Frank V. Brozovich, Rochester, Minnesota, pro se.

Keith Ellison, Attorney General, Joseph Weiner, Assistant Attorney General, Saint Paul, Minnesota, for respondent. ________________________

SYLLABUS

1. The tax court has jurisdiction to decide cases arising under Minnesota tax

law that incorporate federal tax law.

2. The tax court did not err when it determined that the taxpayer was not a real

estate professional.

3. The tax court did not err when it exercised its discretion and found some of

relators’ claimed deductions unsupported by the evidence offered.

Affirmed.

Considered and decided by the court without oral argument.

1 OPINION

MCKEIG, Justice.

This case is an appeal from an order of the Minnesota Tax Court. Relators Angeline

and Frank Brozovich appealed a tax order (Commissioner’s Order) issued by respondent

Commissioner of Revenue (the Commissioner). The Commissioner assessed the

Brozoviches $10,864.58 in unpaid individual income tax, penalties, and interest for tax

years 2019 and 2020. The assessment was based on a finding that the Brozoviches

improperly deducted over $105,000 in losses related to their residential real estate in

Bainbridge Island, Washington.

The primary issue before the tax court was whether Angeline 1 qualified as a “real

estate professional” under Internal Revenue Code § 469(c)(7)(B) for tax years 2019 and

2020. 2 The Brozoviches presented testimony and evidence to the tax court during a one-

day trial. The tax court determined that Angeline did not qualify as a real estate

professional because she failed to submit credible evidence that she met the minimum

requirement of 750 hours or more on qualifying services in support of renting the

Bainbridge Island Property during the years at issue. Brozovich v. Comm’r of Revenue,

1 This opinion refers to Angeline by her first name to avoid confusion since she and her husband, who is also a party to the matter, share a last name. When referenced together, the parties are called “the Brozoviches.” 2 The statute refers to “taxpayers in real property business” rather than “real estate professionals.” I.R.C. § 469(c)(7). The term “real estate professional” derives from Schedule E of IRS Form 1040 (line 43) and is frequently used by the United States Tax Court when analyzing this statute. The Commissioner, tax court, and parties adopted this term throughout their decisions and briefs; we do the same.

2 No. 9545-R, 2024 WL 1149366, at *5–7 (Minn. T.C. Mar. 8, 2024). The tax court also

determined the validity of other deductions stemming from renting the property to the

Brozoviches’ son, credit card interest payments, and a lawncare payment. Id. at *8–9. The

tax court concluded that all three deductions were improperly claimed. Id. The

Brozoviches submitted a petition for writ of certiorari requesting review of the tax court’s

decision. For the reasons stated below, we affirm the tax court’s decision in full.

FACTS

The Bainbridge Island Property and the Brozoviches’ Claimed Losses

Along with their primary residence in Minnesota, Angeline and Frank Brozovich

own a single-family home on almost half an acre on Bainbridge Island in the state of

Washington (Bainbridge Island Property). During 2019 and 2020, they rented out the

Bainbridge Island Property four times. The rental periods totaled 48 nights, 34 of which

were rentals to immediate family members, and generated approximately $2,840.

The Brozoviches timely filed Minnesota income tax returns for 2019 and 2020.

They deducted over $105,000 in losses associated with their rental real estate business.

In February 2022, the Commissioner audited the Brozoviches’ real estate-related

expense deductions and consequent losses. The audit focused on whether Angeline

qualified as a real estate professional under I.R.C. § 469(c)(7). As described more fully

below, meeting this qualification would have allowed Angeline an exemption to the general

rule that rental activities are per se passive, and she could have offset the Brozoviches’

regular income during the years in issue by deducting property-related losses. See id.,

§§ 461(a), 469(c)(2).

3 Relevant Tax Law

Taxpayers are allowed deductions for certain business and investment expenses

under I.R.C. §§ 162 and 212. Generally, an individual is not entitled to a deduction for a

passive activity loss for the year in which that loss is sustained. See I.R.C. § 469(a). A

passive activity is an activity involving conduct of a trade or business in which the taxpayer

does not materially participate. I.R.C. § 469(c)(1). Except as provided in section

469(c)(7), the term “passive activity” includes any rental activity regardless of whether the

taxpayer materially participates. I.R.C. § 469(c)(2), (4).

Section 469(c)(7) provides that rental activities of certain taxpayers in real property

trades or businesses are not per se passive activities under section 469(c)(2) but are treated

as a trade or business subject to the material participation requirements of I.R.C.

§ 469(c)(1)(B). Under section 469(c)(7), real estate owned by the taxpayer but rented to a

third party is not considered passive if, and only if, the taxpayer meets two requirements:

(i) more than one-half of the personal services performed in trades or businesses by the taxpayer during such taxable year are performed in real property trades or businesses in which the taxpayer materially participates, and (ii) such taxpayer performs more than 750 hours of services during the taxable year in real property trades or businesses in which the taxpayer materially participates.

I.R.C. § 469(c)(7)(B)(i–ii) (emphasis added). If both elements are met, the taxpayer may

then deduct any losses the taxpayer has incurred from rental real estate. See I.R.C.

§ 469(a)–(c). The primary issue in this case is whether Angeline qualified as a real estate

professional, which required that she perform the requisite number of hours of services.

4 The Audit

During the audit examining whether Angeline qualified as a real estate professional

under I.R.C. § 469(c)(7), the Brozoviches submitted two sets of data to the Commissioner.

On March 4, 2022, they provided approximately 180 pages of documentation relating to

their real estate business. Angeline included two spreadsheets documenting her hours. The

spreadsheets indicated that Angeline worked on rental real estate activities for 148.5 hours

in 2019 and 89.75 hours in 2020. Nothing in this documentation mentioned a separate or

additional work record associated with her rental real estate business. Instead, the

Brozoviches stated that “[d]ue to the size of this single island cottage rental, all accounting

and business records are maintained on a computer spreadshe[e]t, supported by vendor

receipts and notations.” On March 26, 2022, the Brozoviches sent additional

documentation to the Commissioner, but again they did not reference an additional work

record.

On April 5, 2022, the Commissioner requested that the Brozoviches clarify the

conditions they used to classify Angeline as a real estate professional. On April 26, 2024,

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Angeline R. Brozovich and Frank V. Brozovich, Relators, vs. Commissioner of Revenue, Respondent, Counsel Stack Legal Research, https://law.counselstack.com/opinion/angeline-r-brozovich-and-frank-v-brozovich-relators-vs-commissioner-of-minn-2025.